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OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion to Dismiss for Lack of
Jurisdiction.
The facts pertinent to the disposition of this matter are
summarized below.
Background
Respondent determined deficiencies in petitioners' Federal
income taxes, an addition to tax, and a penalty as follows:
Addition to Tax Penalty
Year Deficiency Sec. 6661 Sec. 6662(a)
1988 $11,846.82 $2,961.71 ---
1990 10,076.82 --- $2,015.36
Duplicate notices of deficiency dated July 8, 1994, were
sent to Fe Green (petitioner) and Joseph Green at 1503 Hastings
Mill Road, Pittsburgh, Pennsylvania, and to P.O. Box 1136, Cherry
Hill, New Jersey. United States Postal Service Form 3877 (Form
3877) reflects that the notices of deficiency were mailed on July
8, 1994. On June 24, 1993, approximately one year prior to the
mailing of the notices of deficiency, petitioner notified the
Internal Revenue Service Appeals Office in Newark, New Jersey
(Appeals), by letter, of Joseph Green's new address in Lyndhurst,
New Jersey. No notice of deficiency was sent to Joseph Green's
Lyndhurst, New Jersey, address.
Petitioners filed a petition seeking a redetermination of
their tax liability for 1988 and 1990. At the time of filing the
petition herein, petitioner resided in Pittsburgh, Pennsylvania,
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